A single show-cause notice or composite assessment order cannot...

A single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.

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